The FG Rheinland-Pfalz In its decision noted v. 17.12.2010, that a tax assessment after a nearly 10 year hiatus criminal tax proceedings may for taxation statute of limitations may be permitted.
that regard, the FG objections to the previous case of BFH, after a timing alone can not lead to the establishment limitation has, therefore, must be accompanied by other circumstances for a forfeiture of the tax claim.
The FG may rely much on his doubts on the current jurisprudence of the ECJ : The ECJ has repeatedly stated that legal proceedings in any case be disproportionate from 10 years of continuous long (eg, Judgement of 17.06.2009, Case 8453/04) are. This also applies to disciplinary proceedings. Thus, there is much to be transferred to the jurisdiction of the ECJ on trial .
The firm KONLUS will discuss the decision of the FG Rheinland-Pfalz in the journal AO Accountants.
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